Analysis from law firm Pinsent Masons found that £11.5bn of the £35.8bn of underpaid tax in the 2020-21 tax year was underpaid by large foreign businesses with US-owned businesses being responsible for 47% of the overall figure.

After large US-owned companies, businesses operating in Switzerland, £825m, and the Republic of Ireland, £674m, make up the top three countries in the list of foreign-owned companies HMRC believes are underpaying UK taxes.

The figures from HMRC reveal that this has cost the tax authority £5.4bn as a result.

Pinsent Masons states that the use of transfer pricing is a major focus for the tax authority in tackling the issue. Transfer pricing represents the price that one division in a company cross-charges to another division for goods and services provided such as intellectual property.